Rowland v. California Men's Colony, Unit II Men's Advisory Council’s Empirical Analysis
1993
Citation profile
239 federal appellate · 162 district · 62 state decisions
How this case has been cited
Cited by 1,140 later decisions (10 by the Supreme Court) — most recently May 2025 · most notably Sundstrand Corp. v. Commissioner (1994), Hubbard v. United States (1995)
239 federal appellate · 162 district · 62 state decisions — followed in 15 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedCalifornia Men's Colony v. Rowland (from Ninth Circuit Court of Appeals)
Relationships
Applies 11 U.S.C. § 101 (Bankruptcy Abuse Prevention and Consumer Protection Act of 2005) · 18 U.S.C. § 244 · 18 U.S.C. § 3118 · 1 U.S.C. § 1 (Born-Alive Infants Protection Act of 2002) · 22 U.S.C. § 262P · 28 U.S.C. § 1654 · 28 U.S.C. § 1827 · 28 U.S.C. § 1915
Relies on Neitzke v. Williams · Caminetti v. United States · United States v. Detroit Timber & Lumber Co. · Osborn v. President Directors and Company of the Bank of the United States · United States v. Kras
Cited together with Bell Atlantic Corp. v. Twombly · Ashcroft v. Iqbal · Anderson v. Liberty Lobby, Inc. · Erickson v. Pardus · Lujan v. Defenders of Wildlife
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 1,140 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[i]t has been the law for the better part of two centuries ... that a corporation may appear in the federal courts only through licensed counsel. As the courts have recognized, the rationale for that rule applies equally to all artificial entities. Thus, save a few aberrant cases, the lower courts have uniformly held that 28 U.S.C. § 1654 , providing that “parties may plead and conduct their own cases personally or by counsel,” does not allow corporations, partnerships, or associations to appear in federal court otherwise than through a licensed attorney.”
21 later decisions quote this exact passage · from the majority“[Ojne can say that “indicates” certainly imposes less of a burden than, say, “requires” or “necessitates.” One can also say that this exception from the general rule would be superfluous if the context “indicate[d] otherwise” only when use of the general definition would be incongruous enough to invoke the common mandate of statutory construction to avoid absurd results. In fine, a contrary “indication” may raise a specter short of inanity, and with something less than syllogistic force.”
7 later decisions quote this exact passage · from the majority“the text of the Act of Congress surrounding the word at issue, or the texts of other related congressional Acts, and this is simply an instance of the word’s ordinary meaning: ‘[t]he part or parts of a discourse preceding or following a ‘text’ or passage or a word, or so intimately associated with it as to throw light upon its meaning.”
4 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.